Conflicts of Interest in 2025: Navigating Disclosure, Risk, and Accountability

A conflict of interest (COI) arises when personal relationships, financial interests or outside activities influence, or appear to influence, an employee’s judgment. A COI program helps organizations identify, assess and resolve these risks early. 

During our recent webinar, speaker Michael Volkov emphasized that undisclosed conflicts, especially at senior levels, can erode trust quickly and undermine culture. Employees notice when leaders are held to different standards, which makes COI governance an important indicator of accountability and integrity.

A good rule of thumb is simple: everyone. 
While senior leaders, people managers and procurement roles carry heightened exposure, all employees can encounter potential conflicts. Asking every employee to complete a disclosure reinforces fairness and encourages a speak-up culture. 

New hires should complete a disclosure during onboarding, and all employees should reconfirm annually. Volkov noted that treating all roles consistently helps create a culture where transparency is expected.

Best practice includes: 

• Annual disclosures for all employees 
• New-hire disclosures during onboarding 
• Interim disclosures when a situation changes 

Technology can streamline this workflow by repopulating past answers and prompting employees to confirm whether details remain accurate. This reduces administrative burden while improving completeness.

Most organizations use a tiered approach: 

• Compliance manages day-to-day reviews 
• An internal ethics committee (typically Compliance, HR, Legal) handles complex or sensitive cases 
• Escalation paths guide issues involving senior executives 

A formal escalation policy helps avoid real or perceived bias and ensures that reviews are handled consistently. This structure is essential for fairness and credibility.

Boards should receive regular compliance reporting, including COI metrics and trends. DOJ expectations reinforce that boards must have visibility into the health of an organization’s culture.  

However, individual COI cases are usually reviewed by internal ethics committees unless the disclosure involves: 

• A senior executive 
• A potential risk to shareholders 
• A matter that may require regulatory reporting 

Boards mostly need oversight, not immersion in operational decisions.

Documentation is one of the strongest indicators of accountability. 

Regulators expect organizations to: 

• Show how disclosures were reviewed 
• Demonstrate who was involved 
• Record the rationale behind decisions 
• Maintain an audit trail 

As Michael Volkov noted, “If you cannot produce documentation, regulators will not believe you.”

Clear COI policies typically address: 

• Definitions and examples of conflicts 
• Annual and interim disclosure expectations 
• Escalation and review processes 
• Roles and responsibilities 
• Conditions for approval (for example, recusal from certain decisions) 
• How the organization manages gift- and entertainment-related conflicts 

Simple and consistent language helps remove ambiguity and reinforces fairness.

Provide employees with examples across a spectrum. For instance: 

• Serving on a PTO board may not pose a conflict 
• Serving on the board of an industry association, vendor or competitor may require disclosure 

The key is perception. Even if a situation is not an actual conflict, the appearance of one can damage trust. Clear definitions and relatable examples help employees understand when to disclose.

Gifts, meals, entertainment and travel (GMET) are among the most common sources of conflicts. Expectations should include: 

• Dollar limits 
• Approval thresholds 
• Required disclosures 
• Clear examples of acceptable and unacceptable situations 

Because this is a seasonal pain point, especially during the holidays, employees benefit from quick access to guidance such as micro-learnings or automated policy lookup tools.

Fairness requires: 

• Standardized review workflows 
• Consistent criteria for decisions 
• Clear escalation paths 
• Transparency when possible 
• Documentation of reasoning 

Organizations should periodically review trends to confirm that decisions are being applied evenly.

Employees value transparency, but confidentiality must be preserved. Many organizations share de-identified examples in: 

• Annual ethics reports 
• All-hands meetings 
• Training 
• Internal newsletters 

Volkov noted that anonymized summaries help strengthen culture by showing that concerns are taken seriously.

Manual processes such as email, spreadsheets and inbox archives create inconsistency and risk. Modern COI technology reduces workload through: 

• Automated routing rules 
• Risk scoring 
• Pre-populated disclosures 
• Built-in communication tools 
• Role-based access 
• Analytics and dashboards 

Large organizations especially benefit from automation because they may manage thousands of disclosures each year.

Anonymous reporting is usually handled through the hotline. For disclosures: 

• Some platforms support proxy entry by administrators 
• NAVEX confirmed that enhanced proxy support is planned as an upcoming feature 

This helps employees who may need assistance while still maintaining process integrity.

Yes. Integrations support: 

• New-hire disclosure automation 
• Role-based questionnaire assignments 
• Data consistency 
• Reduced manual entry 
• Targeted outreach to higher-risk groups 

When COI data is paired with HR or vendor data, teams can also identify relationships or activities that require closer review.

Analytics can uncover insights such as: 

• Multiple disclosures involving the same vendor 
• Clusters of outside employment in a department 
• Trends in gift- or relationship-based conflicts 
• Increases in anonymous reporting 

During the webinar, one example highlighted how more than a dozen employees in the same department had outside employment with the same company. This pattern only became clear through analytics.

COIs often appear alongside other risks, including fraud, bribery and third-party misconduct. Volkov noted that many bribery or trade violations begin with an overlooked or undisclosed conflict.  

This makes COI data valuable for: 

• ABAC programs 
• Third-party screening 
• Vendor selection 
• Whistleblowing trends 
• Culture assessments

While DOJ does not issue COI-specific regulations, its expectations remain clear. Organizations should demonstrate: 

• A strong culture of compliance 
• Leadership accountability 
• Effective reporting channels 
• Board visibility 
• Documented and consistent processes 
• Timely investigation and resolution 

COI handling is often viewed as a reflection of broader compliance maturity.

Explore additional resources, including: 

• NAVEX Resource Center 
• The 2025 NAVEX Benchmark Report 
• NAVEX One Disclosure Management 
• Webinars on speak-up culture and ethical leadership